Facts:

The case revolves around 20th Century Fox Film Corporation (hereinafter referred to as "the petitioner") as the petitioner against the Court of Appeals, Eduardo M. Barreto, Raul Sagullo, and Fortune Ledesma (the respondents) concerning G.R. Nos. 76649-51. On August 19, 1988, the Supreme Court issued its decision regarding this case initially filed with the Regional Trial Court of Makati. On August 26, 1985, the petitioner, through counsel, submitted a letter-complaint to the National Bureau of Investigation (NBI). This letter sought the NBI's assistance in conducting searches and seizures linked to an anti-film piracy campaign. It specifically reported unauthorized sales and rentals of copyrighted films by certain video outlets across Metro Manila. Acting on this, the NBI conducted surveillance and investigations, which led to the filing of three consolidated applications for search warrants against the video outlets owned by Barreto, Sagullo, and Ledesma. On Septe

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Facts:

Background and Initiation

• Petitioner, 20th Century Fox Film Corporation, filed a letter-complaint dated August 26, 1985, seeking the National Bureau of Investigation’s (NBI) assistance in combating film piracy.
• The complaint alleged that various videotape outlets throughout Metro Manila were engaged in the unauthorized sale and rental of copyrighted films, thus violating Presidential Decree No. 49 on the protection of intellectual property.

NBI Investigation and Issuance of Search Warrants

• Acting on the petitioner’s complaint, the NBI conducted surveillance and investigation at the video outlets identified by the petitioner.
• Based on its findings, the NBI filed three separate applications for search warrants against the establishments owned by the private respondents.
• The applications were consolidated and heard by the Regional Trial Court (RTC) of Makati, Branch 132, which, on September 4, 1985, issued the corresponding search warrants.

Execution of the Search and Subsequent Orders

• With the search warrants in hand, NBI agents, accompanied by petitioner's agents, raided the targeted video outlets, seizing various items.
• An inventory was made of the seized items, which was subsequently left with the private respondents.
• Private respondents moved to have the search warrants lifted and the seized property returned. In response, the RTC issued an order on October 8, 1985, lifting the three search warrants and setting guidelines for the return of the confiscated items.

Motion for Reconsideration and Petition for Certiorari

• The petitioner filed a motion for reconsideration, which was denied in an order dated January 2, 1986.
• Dissatisfied with the lower court’s treatment of the evidence and its consequent findings regarding probable cause, the petitioner elevated the issue by filing a petition for certiorari with the Court of Appeals.
• The core of the dispute centered on the interpretation and application of the constitutional provision against illegal searches and seizures—specifically, whether the earlier search warrants were issued based on sufficient probable cause.

Evidentiary Concerns and Presentation of Master Tapes

• The petitioner contended that the search warrants were justified since they were issued on the basis of witness depositions (taken under oath) that established probable cause.
• A critical element in the petitioner’s evidence was the existence of “master tapes” purportedly belonging to the petitioner, which were to serve as a basis for comparing the allegedly pirated videotapes.
• The lower court, however, noted significant discrepancies in the testimony of the National Bureau of Investigation’s witnesses, who largely lacked personal knowledge of the piracy claims, and it observed that the master tapes were never presented in court.

Issue:

Sufficiency of Probable Cause

• Whether the search warrants issued were based on sufficient and competent evidence establishing probable cause as required by the Constitution.
• Whether the reliance on witness depositions lacking personal knowledge—and the absence of the presentation of master tapes—invalidated the determination of probable cause.

Validity of the Search Warrants

• Whether the general and broad description of the articles to be seized under the search warrants, including items such as television sets and video cassette recorders, constituted an unconstitutional overreach.
• Whether the inclusion of items not exclusively linked to copyright piracy (but rather common in legitimate video outlet operations) rendered the search warrant too general, thus acting against established constitutional safeguards.

Judicial Discretion and Corrective Measures

• Whether the lower court’s decision to lift the search warrants was a proper exercise of its discretion in light of conflicting evidence.
• Whether the actions taken by the court were motivated by the need to rectify an error that could potentially infringe upon the constitutional rights of the private respondents.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)